Patricia Lewis Discusses OECD Discussion Draft at Transfer Pricing Conference

International Tax Monitor

During a recent transfer pricing conference, Caplin & Drysdale's, Patricia Gimbel Lewis discussed a discussion draft on risk and recharacterization, which was released in December 2014 as part of the OECD's base erosion and profit shifting (BEPS) project. For the complete article, please click on the link above to view a branded PDF.

Excerpt taken from the article.

"I think it is almost as inappropriate to assign a risk-free rate of return to the capital," said Patricia Lewis, a member of Caplin & Drysdale in Washington. "That just strikes me as being at odds with the arm's-length principle."


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